Telangana High Court Overturns Commercial Court's Decision on Late Document Filing in Construction Disputes

Court Emphasizes Strict Compliance with Disclosure Requirements Under CPC and Commercial Courts Act

In a significant ruling, the Telangana High Court has set aside the orders of the Commercial Court, Ranga Reddy District, which allowed M/s Sri Vishnu Constructions to introduce additional documents into evidence after the filing of their written statements in two ongoing commercial suits. The Division Bench, comprising Justices Moushumi Bhattacharya and Gadi Praveen Kumar, emphasized the necessity for strict adherence to procedural rules as outlined in the Civil Procedure Code (CPC), 1908, and the Commercial Courts Act, 2015.

The case arose from civil revision petitions filed by M/s Sri Vishnu Constructions against the State of Telangana, challenging the Commercial Court's orders that permitted the late filing of documents. These documents were initially omitted during the submission of written statements in two lawsuits concerning recovery claims of over Rs. 14 crore. The Commercial Court's decision was based on the rationale that the documents were referenced in the written statements and not contested by the plaintiffs.

However, the High Court found this reasoning flawed, highlighting that mere reference to documents does not satisfy the requirement of 'reasonable cause' for their delayed submission, as mandated by Order XI Rule 1(10) of the CPC. The Court underscored that the procedural rigour under the amended CPC is intended to expedite the resolution of commercial disputes by preventing delays caused by late document submissions.

The High Court further noted that the defendants failed to establish a substantial cause for the delay, merely citing the misplacement and subsequent rediscovery of documents as reasons. This justification was deemed inadequate, as it did not align with the legislative intent behind the disclosure norms.

In its ruling, the High Court reiterated the importance of the defendants' obligation to file all relevant documents at the time of submitting their written statements, as per Order XI Rule 1(7)-(9) of the CPC. The Court emphasized that the objective of the Commercial Courts Act, 2015, is to ensure swift adjudication of commercial suits, which can be hindered by lax compliance with procedural requirements.

The decision has significant implications for commercial litigation, reinforcing the judiciary's commitment to ensuring procedural discipline and expeditious legal processes. As a result, the impugned orders dated June 10, 2025, have been set aside, and the connected applications dismissed, with no costs awarded.

Bottom Line:

Commercial suits - Filing of additional documents by defendant after written statement - Mere reference to documents in written statement does not constitute 'reasonable cause' for non-disclosure during the filing of the written statement under Order XI Rule 1(10) of CPC, as amended by the 2015 Act.

Statutory provision(s): Civil Procedure Code, 1908 - Order XI Rule 1(10), Commercial Courts Act, 2015, Order XI Rule 1(7)-(9)

M/s. Sri Vishnu Constructions v. State of Telangana, (Telangana)(DB) : Law Finder Doc Id # 2813608